The Director Of Income Tax, Delhi Versus LS Cable Limited

2016 (1) TMI 1126 - DELHI HIGH COURT

Income deemed to accrue or arise in India - tax liability - Agreement for Avoidance of Double Taxation between India and Korea - PE in India - Held that:- The point sought to be urged is covered against the Revenue by two decisions of this Court conc .....

sufficient business connection to take the PE as a taxable entity more so, as the cl. (a) of Expln. 1 to s. 9(1)(i) of the Act emphasizes that only such part of the income as is attributable to the operations carried out in India could be taxed in I .....